BRUSSELS, 3 November — An industry assessment published on 2 November estimated that approximately six in ten exporters supplying goods covered by the European Union’s Carbon Border Adjustment Mechanism (CBAM) have gaps in emissions documentation and verification readiness. The finding points to a data challenge for suppliers ahead of the definitive regime, which applies to covered imports from 2026.
Based on assessments by accredited verification providers, the estimate concerns exporters of steel, aluminium, cement, fertilisers, hydrogen and electricity. It is an industry assessment, not a statistically established measure of readiness across all exporters, because detailed sampling information has not been publicly established.
The issue affects suppliers in Serbia, Montenegro, Bosnia and Herzegovina and other Southeast European markets. For them, the assessment identifies emissions evidence as both a compliance matter and a market-access issue, as European buyers may increasingly favour suppliers able to provide verified information before shipment, particularly for large-volume purchases and long-term contracts.
Product-level evidence needed
European importers seeking to use actual embedded emissions must obtain appropriate installation-level information and independent verification. Factories outside the EU may have sustainability reports or corporate carbon inventories, but those records do not automatically establish emissions for a specific exported steel product, aluminium batch or cement installation.
Emissions calculations can require production-specific records covering fuel consumption, process emissions, relevant precursor inputs, monitoring boundaries and allocation methodologies. Where actual emissions are unavailable or insufficiently supported, importers may need to use regulatory default values. The assessment notes that those values can put producers at a commercial disadvantage when their actual emissions are lower.
The first annual CBAM declarations are due in September 2027. A shortage of usable emissions evidence could affect procurement decisions even before the first annual CBAM settlement, according to the assessment.
Implications for buyers and finance
European buyers’ preference for verified information may influence supplier selection before shipment, while banks financing industrial exporters may need to distinguish companies with credible emissions evidence from those whose sales prices remain exposed to uncertain carbon-cost deductions.
Verification providers are facing increasing demand, making early engagement and confirmation of accreditation scope important for exporters seeking to support actual-emissions reporting. The assessment identifies the need for installation-level data and independent verification as suppliers prepare for the 2026 definitive regime.
